(1) Dividends paid by a ccmpany which is a resident
of a Contracting State to a resident of the other Con-
tracting State may be taxed in that other State.
(2) However, such dividends may be taxed in the
Contracting State of which the company paying the
dividends is a resident, and according to the law of that
State, but the tax so charged shall not exceed:
a) 10 per cent of the gross amount of the dividends if
the recipient is a company which itself, or jointly
within a partnership with other companies, holds at
least 25 per cent of the capital of the company paying
the dividends;
b) in all other cases, 15 per cent of the gross amount
of the dividends.
(3) Notwithstanding the provisions of paragraph (2),
the tax of a Contracting State on dividends paid by a
company which is a resident of that State may exceed
the rates provided for in that paragraph, but shall not
exceed 25.75 per cent of the gross amount of the
dividends, if
a) the rate of the corporation tax of that State on
distributed profits is lower than that on undistributed
profits and the difference between those two rates
is 20 percentage points or more, and
b) such dividends are paid by a company which is a
resident of that State to a company which is a resident
of the other Contracting State and which itself or
together with other persons controlling it or being
under common control with it, holds, directly or in-
directly, at least 25 per cent of the capital of the
first-mentioned company.
(4) The term “dividends” as used in this Article means
income from shares, mining shares, tounders’ shares or
other rights, not being debt-claims, participating in
profits, as well as income from other corporate rights
assimilated to income from shares by the taxation law
of the State of which the company making the distribu-
tion is a resident, and income derived by a sleeping
partner trom his participation as such and distributions
on certificates of an investment-trust.
(5} The provisions of paragraphs (1) to (3) shall not
apply if the recipient of the dividends, being a resident
of a Contracting State, has in the other Contracting
State, of which the company paying the dividends is a
resident, a permanent establishment with which the
holding by virtue ot which the dividends are paid is
effectively connected. In such a case, the provisions
of Article 7 shall apply.
(6) Where a company which is a resident of a Con-
tracting State derives profits or income from the other
Contracting State, that other State may not impose any
tax on the dividends paid by the company to persons
who are not residents of that other State, or subject
the company's undistributed profits to a tax on un-
distributed profits, even if the dividends paid or the
undistributed profits consist wholly or partly of profits
or income arising in such other State.
de-liberia-1973-base | BGBl. 1973 II S. 1285 | signed 1970-11-25 | published 1973-09-06 | Signed: 1970-11-25 | Gazette publication: 1973-09-06
Source form
unchanged official-publication scan; separate 260-dpi local OCR machine transcription, NOT original native text
Source scope
original consent-law publication and base treaty with accompanying protocol; not current consolidated law
Retrieved
2026-09-30
Text and language scope
The original closing specifies German and English, equally authentic. No third authentic language is identified by these retained originals/audit; this is not a full-language accuracy certification. All text is unreviewed OCR, including retained wrong glyphs, punctuation, hyphens and spacing. Treaty preamble, closing, protocol, signatures, implementing law and any notes are retained separately at /review/de-liberia-1973-base/. Exact physical-page spans and unresolved OCR at /review/de-liberia-1973-base/evidence/. Source-page links are page references, not verified paragraph alignment.
Review status
Pending human wording, completeness, source authority, currentness, alignment and rendering review. No legal review performed.
Currentness
Original source edition; not a verified current-law consolidation. Unknown as current law. Signed 1970-11-25; consent law 1973-08-30; gazette publication 1973-09-06. Edition ID year is not a signature date. Treaty entry into force: 1974-04-25. Roster general application: 1970-01-01 (not a universal tax-specific rule). Cached official article entry statements (may refer to multiple instruments): 25. April 1974. Evidence is the retained 2026-10-01 agent audit of source PDF, 2026-01-01 roster and cached official HTML, not a fresh current-law determination. Bounded agent triage, no qualified wording/alignment/legal review. No exhaustive verification of all later 2026 developments. Matching digest proves retained source identity, not legal force.
Protocols and later instruments
Printed signature protocol retained separately and not merged into articles. Roster future-instrument/negotiation entry (NOT proof of operative amendment): Liberia R-A V. P = Paraphierung (initialled), NOT signature; U = signed, ratification pending; V = negotiation. R-P protocol/R-A replacement. MLI application and complete later amendments, replacements or suspensions are NOT verified. No developments after the retained roster snapshot are certified. This is NOT a current consolidated instrument. Source-triage warnings: Bounded agent triage, no qualified wording/alignment/legal review. No exhaustive verification of all later 2026 developments. Matching digest proves retained source identity, not legal force.
Text language and status
en · authentic-language-transcription · machine-transcription
BGBl. 1973 II S. 1285 | de-liberia-1973-base | de-liberia-1973-base | BGBl. 1973 II S. 1285 | signed 1970-11-25 | published 1973-09-06 | Signed: 1970-11-25 | Gazette publication: 1973-09-06 | Article 10 | en | Pending human wording, completeness, source authority, currentness, alignment and rendering review. No legal review performed. | /library/treaties/de-liberia-1973-base/en/articles/article-10/
Source, edition and limits
Source edition
de-liberia-1973-base | BGBl. 1973 II S. 1285 | signed 1970-11-25 | published 1973-09-06 | Signed: 1970-11-25 | Gazette publication: 1973-09-06
Source form
unchanged official-publication scan; separate 260-dpi local OCR machine transcription, NOT original native text
Source scope
original consent-law publication and base treaty with accompanying protocol; not current consolidated law
Retrieved
2026-09-30
Text and language scope
The original closing specifies German and English, equally authentic. No third authentic language is identified by these retained originals/audit; this is not a full-language accuracy certification. All text is unreviewed OCR, including retained wrong glyphs, punctuation, hyphens and spacing. Treaty preamble, closing, protocol, signatures, implementing law and any notes are retained separately at /review/de-liberia-1973-base/. Exact physical-page spans and unresolved OCR at /review/de-liberia-1973-base/evidence/. Source-page links are page references, not verified paragraph alignment.
Review status
Pending human wording, completeness, source authority, currentness, alignment and rendering review. No legal review performed.
Currentness
Original source edition; not a verified current-law consolidation. Unknown as current law. Signed 1970-11-25; consent law 1973-08-30; gazette publication 1973-09-06. Edition ID year is not a signature date. Treaty entry into force: 1974-04-25. Roster general application: 1970-01-01 (not a universal tax-specific rule). Cached official article entry statements (may refer to multiple instruments): 25. April 1974. Evidence is the retained 2026-10-01 agent audit of source PDF, 2026-01-01 roster and cached official HTML, not a fresh current-law determination. Bounded agent triage, no qualified wording/alignment/legal review. No exhaustive verification of all later 2026 developments. Matching digest proves retained source identity, not legal force.
Protocols and later instruments
Printed signature protocol retained separately and not merged into articles. Roster future-instrument/negotiation entry (NOT proof of operative amendment): Liberia R-A V. P = Paraphierung (initialled), NOT signature; U = signed, ratification pending; V = negotiation. R-P protocol/R-A replacement. MLI application and complete later amendments, replacements or suspensions are NOT verified. No developments after the retained roster snapshot are certified. This is NOT a current consolidated instrument. Source-triage warnings: Bounded agent triage, no qualified wording/alignment/legal review. No exhaustive verification of all later 2026 developments. Matching digest proves retained source identity, not legal force.
Text language and status
en · authentic-language-transcription · machine-transcription